September 17, 2015

Exemption No. 12911

Regulatory Docket No. FAA20152139

Mr. Kurt Wimmer

Counsel for NFL Productions LLC dba NFL Films
One CityCenter
850 Tenth Street, NW.
Washington, DC 20001-4956
Dear Mr. Wimmer:
This letter is to inform you that we have granted your request for exemption. It transmits our
decision, explains its basis, and gives you the conditions and limitations of the exemption,
including the date it ends.
By letters dated May 20, 2015, and August 11, 2015, you petitioned the Federal Aviation
Administration (FAA) on behalf of NFL Productions LLC dba NFL Films (hereinafter
petitioner or operator) for an exemption. The petitioner requested to operate an unmanned
aircraft system (UAS) to conduct aerial videography and closed-set motion picture and
television filming.
See Appendix A for the petition submitted to the FAA describing the proposed operations and
the regulations that the petitioner seeks an exemption.
The FAA has determined that good cause exists for not publishing a summary of the petition
in the Federal Register because the requested exemption would not set a precedent, and any
delay in acting on this petition would be detrimental to the petitioner.
Airworthiness Certification
The UAS proposed by the petitioner are the DJI Phantom 1, DJI Phantom 2, and DJI Inspire
1.

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The petitioner requested relief from 14 CFR part 21, Certification procedures for products
and parts, Subpart HAirworthiness Certificates. In accordance with the statutory criteria
provided in Section 333 of Public Law 11295 in reference to 49 U.S.C. 44704, and in
consideration of the size, weight, speed, and limited operating area associated with the
aircraft and its operation, the Secretary of Transportation has determined that this aircraft
meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from
14 CFR part 21, Certification procedures for products and parts, Subpart HAirworthiness
Certificates, and any associated noise certification and testing requirements of part 36, is
not necessary.
The Basis for Our Decision
You have requested to use a UAS for aerial data collection1 and closed set motion picture and
filming. The FAA has issued grants of exemption in circumstances similar in all material
respects to those presented in your petition. In Grants of Exemption Nos. 11062 to Astraeus
Aerial (see Docket No. FAA20140352), 11109 to Clayco, Inc. (see Docket No.
FAA20140507), 11112 to VDOS Global, LLC (see Docket No. FAA20140382), and
11213 to Aeryon Labs, Inc. (see Docket No. FAA20140642), the FAA found that the
enhanced safety achieved using an unmanned aircraft (UA) with the specifications described
by the petitioner and carrying no passengers or crew, rather than a manned aircraft of
significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA
good cause to find that the UAS operation enabled by this exemption is in the public interest.
Having reviewed your reasons for requesting an exemption, I find that

They are similar in all material respects to relief previously requested in Grant of
Exemption Nos. 11062, 11109, 11112, and 11213;
The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and
11213 also apply to the situation you present; and
A grant of exemption is in the public interest.

Our Decision
In consideration of the foregoing, I find that a grant of exemption is in the public interest.
Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701,
delegated to me by the Administrator, NFL Productions LLC dba NFL Films is granted an
exemption from 14 CFR 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a),
91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and
91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform
1

Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA.
Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF
analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by
instruments aboard the UA.

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aerial data collection and closed set motion picture and filming. This exemption is subject to
the conditions and limitations listed below.
Conditions and Limitations
In this grant of exemption, NFL Productions LLC dba NFL Films is hereafter referred to as
the operator.
Failure to comply with any of the conditions and limitations of this grant of exemption will be
grounds for the immediate suspension or rescission of this exemption.
1. Operations authorized by this grant of exemption are limited to the DJI Phantom 1,
DJI Phantom 2, and DJI Inspire 1 when weighing less than 55 pounds including
payload. Proposed operations of any other aircraft will require a new petition or a
petition to amend this exemption.
2. Operations for the purpose of closed-set motion picture and television filming
are permitted.
3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The
exemption holder may use either groundspeed or calibrated airspeed to determine
compliance with the 87 knot speed restriction. In no case will the UA be operated at
airspeeds greater than the maximum UA operating airspeed recommended by the
aircraft manufacturer.
4. The UA must be operated at an altitude of no more than 400 feet above ground level
(AGL). Altitude must be reported in feet AGL.
5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times.
This requires the PIC to be able to use human vision unaided by any device other than
corrective lenses, as specified on the PICs FAA-issued airman medical certificate or
U.S. drivers license.
6. All operations must utilize a visual observer (VO). The UA must be operated within
the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used
to satisfy the VLOS requirement as long as the PIC always maintains VLOS
capability. The VO and PIC must be able to communicate verbally at all times;
electronic messaging or texting is not permitted during flight operations. The PIC
must be designated before the flight and cannot transfer his or her designation for the
duration of the flight. The PIC must ensure that the VO can perform the duties
required of the VO.
7. This exemption and all documents needed to operate the UAS and conduct its
operations in accordance with the conditions and limitations stated in this grant of

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exemption, are hereinafter referred to as the operating documents. The operating
documents must be accessible during UAS operations and made available to the
Administrator upon request. If a discrepancy exists between the conditions and
limitations in this exemption and the procedures outlined in the operating documents,
the conditions and limitations herein take precedence and must be followed.
Otherwise, the operator must follow the procedures as outlined in its operating
documents. The operator may update or revise its operating documents. It is the
operators responsibility to track such revisions and present updated and revised
documents to the Administrator or any law enforcement official upon request. The
operator must also present updated and revised documents if it petitions for extension
or amendment to this grant of exemption. If the operator determines that any update
or revision would affect the basis upon which the FAA granted this exemption, then
the operator must petition for an amendment to its grant of exemption. The FAAs
UAS Integration Office (AFS80) may be contacted if questions arise regarding
updates or revisions to the operating documents.
8. Any UAS that has undergone maintenance or alterations that affect the UAS operation
or flight characteristics, e.g., replacement of a flight critical component, must undergo
a functional test flight prior to conducting further operations under this exemption.
Functional test flights may only be conducted by a PIC with a VO and must remain at
least 500 feet from other people. The functional test flight must be conducted in such
a manner so as to not pose an undue hazard to persons and property.
9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is
in a condition for safe operation.
10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the
UAS is in a condition for safe flight. The pre-flight inspection must account for all
potential discrepancies, e.g., inoperable components, items, or equipment. If the
inspection reveals a condition that affects the safe operation of the UAS, the aircraft is
prohibited from operating until the necessary maintenance has been performed and the
UAS is found to be in a condition for safe flight.
11. The operator must follow the UAS manufacturers maintenance, overhaul,
replacement, inspection, and life limit requirements for the aircraft and
aircraft components.
12. Each UAS operated under this exemption must comply with all manufacturer
safety bulletins.
13. Under this grant of exemption, a PIC must hold either an airline transport,
commercial, private, recreational, or sport pilot certificate. The PIC must also hold a
current FAA airman medical certificate or a valid U.S. drivers license issued by a
state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal

5
government. The PIC must also meet the flight review requirements specified in
14 CFR 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.
14. The operator may not permit any PIC to operate unless the PIC demonstrates the
ability to safely operate the UAS in a manner consistent with how the UAS will be
operated under this exemption, including evasive and emergency maneuvers and
maintaining appropriate distances from persons, vessels, vehicles and structures. PIC
qualification flight hours and currency must be logged in a manner consistent with
14 CFR 61.51(b). Flights for the purposes of training the operators PICs and VOs
(training, proficiency, and experience-building) and determining the PICs ability to
safely operate the UAS in a manner consistent with how the UAS will be operated
under this exemption are permitted under the terms of this exemption. However,
training operations may only be conducted during dedicated training sessions. During
training, proficiency, and experience-building flights, all persons not essential for
flight operations are considered nonparticipants, and the PIC must operate the UA
with appropriate distance from nonparticipants in accordance with 14 CFR 91.119.
15. UAS operations may not be conducted during night, as defined in 14 CFR 1.1. All
operations must be conducted under visual meteorological conditions (VMC). Flights
under special visual flight rules (SVFR) are not authorized.
16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as
denoted in the current FAA Airport/Facility Directory (AFD) or for airports not
denoted with an ARP, the center of the airport symbol as denoted on the current
FAA-published aeronautical chart, unless a letter of agreement with that airports
management is obtained or otherwise permitted by a COA issued to the exemption
holder. The letter of agreement with the airport management must be made available
to the Administrator or any law enforcement official upon request.
17. The UA may not be operated less than 500 feet below or less than 2,000 feet
horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.
18. If the UAS loses communications or loses its GPS signal, the UA must return to a
pre-determined location within the private or controlled-access property.
19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.
20. The PIC is prohibited from beginning a flight unless (considering wind and forecast
weather conditions) there is enough available power for the UA to conduct the
intended operation and to operate after that for at least five minutes or with the reserve
power recommended by the manufacturer if greater.
21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All
operations shall be conducted in accordance with an ATO-issued COA. The

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exemption holder may apply for a new or amended COA if it intends to conduct
operations that cannot be conducted under the terms of the attached COA.
22. All aircraft operated in accordance with this exemption must be identified by serial
number, registered in accordance with 14 CFR part 47, and have identification
(NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings must
be as large as practicable.
23. Documents used by the operator to ensure the safe operation and flight of the UAS and
any documents required under 14 CFR 91.9 and 91.203 must be available to the
PIC at the Ground Control Station of the UAS any time the aircraft is operating.
These documents must be made available to the Administrator or any law enforcement
official upon request.
24. The UA must remain clear and give way to all manned aviation operations and
activities at all times.
25. The UAS may not be operated by the PIC from any moving device or vehicle.
26. All Flight operations must be conducted at least 500 feet from all nonparticipating
persons, vessels, vehicles, and structures unless:
a. Barriers or structures are present that sufficiently protect nonparticipating persons
from the UA and/or debris in the event of an accident. The operator must ensure
that nonparticipating persons remain under such protection. If a situation arises
where nonparticipating persons leave such protection and are within 500 feet of
the UA, flight operations must cease immediately in a manner ensuring the safety
of nonparticipating persons; and
b. The owner/controller of any vessels, vehicles or structures has granted permission
for operating closer to those objects and the PIC has made a safety assessment of
the risk of operating closer to those objects and determined that it does not
present an undue hazard.
The PIC, VO, operator trainees or essential persons are not considered
nonparticipating persons under this exemption.
27. All operations shall be conducted over private or controlled-access property with
permission from the property owner/controller or authorized representative.
Permission from property owner/controller or authorized representative will be
obtained for each flight to be conducted.
28. Any incident, accident, or flight operation that transgresses the lateral or vertical
boundaries of the operational area as defined by the applicable COA must be reported
to the FAA's UAS Integration Office (AFS80) within 24 hours. Accidents must be

7
reported to the National Transportation Safety Board (NTSB) per instructions
contained on the NTSB Web site: www.ntsb.gov.
If this exemption permits operations for the purpose of closed-set motion picture and
television filming and production, the following additional conditions and limitations apply.
29. The operator must have a motion picture and television operations manual (MPTOM)
as documented in this grant of exemption.
30. At least 3 days before aerial filming, the operator of the UAS affected by this
exemption must submit a written Plan of Activities to the local Flight Standards
District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day
notification may be waived with the concurrence of the FSDO. The plan of activities
must include at least the following:
a. Dates and times for all flights;
b. Name and phone number of the operator for the UAS aerial filming conducted
under this grant of exemption;
c. Name and phone number of the person responsible for the on-scene operation of
the UAS;
d. Make, model, and serial or NNumber of UAS to be used;
e. Name and certificate number of UAS PICs involved in the aerial filming;
f. A statement that the operator has obtained permission from property owners
and/or local officials to conduct the filming production event; the list of those
who gave permission must be made available to the inspector upon request;
g. Signature of exemption holder or representative; and
h. A description of the flight activity, including maps or diagrams of any area, city,
town, county, and/or state over which filming will be conducted and the altitudes
essential to accomplish the operation.
31. Flight operations may be conducted closer than 500 feet from participating persons
consenting to be involved and necessary for the filming production, as specified in the
exemption holders MPTOM.
Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS
operations must comply with all applicable parts of 14 CFR including, but not limited to,
parts 45, 47, 61, and 91.

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This exemption terminates on September 30, 2017, unless sooner superseded or rescinded.
Sincerely,
/s/
John S. Duncan
Director, Flight Standards Service

Enclosures

May 20, 2015

U.S. Department of Transportation
Document Management System
1200 New Jersey Ave., SE
Washington, DC 20590
To Whom It May Concern:
Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14
C.F.R., Part 11, NFL Productions LLC d/b/a NFL Films (NFL Films), operator of Small
Unmanned Aircraft Systems (sUAS) equipped to conduct aerial videography of professional
football game and training facilities, requests a limited exemption from the below-listed
regulations to allow commercial operation of its sUASs, provided that the proposed sUAS
operations comply with the conditions outlined below or as established by the Federal Aviation
Administration (FAA) under Section 333.
The name and address of the applicant is: NFL Productions LLC, One Sabol Way, Mt.
Laurel, N.J. 08054, c/o Barry M. Wolper, Chief Financial Officer, (856) 222-3545,
barry.wolper@nfl.com.
NFL Films makes this request under the summary grant process that the FAA
announced in April 2015. 1 This request is similar in all material respects to a number of recent
grants of exemption, including Grant of Exemption No. 11488 to Advanced Aerial
Cinematography, LLC (FAA Docket No. 2014-0090). 2
Regulations from which the exemption is requested:
14 C.F.R. part 21
14 C.F.R. 45.23 (b)
14 C.F.R. 61.113 (a) & (b)
See FAA Summary Grants Speed UAS Exemptions, available at
https://www.faa.gov/news/updates/?newsId=82485.
1

The use limitations and arguments in this application are nearly identical to those contained in
Advanced Aerial Cinematographys November 24, 2014 application and the FAAs May 5, 2015
approval of that application.
2

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May 20, 2015
Page 2

14 C.F.R. 91.7 (a)

14 C.F.R. 91.9 (b) (2)
14 C.F.R. 91.103
14 C.F.R. 91.109
14 C.F.R. 91.119
14 C.F.R. 91.121
14 C.F.R. 91.151 (a)
14 C.F.R. 91.203 (a) & (b)
14 C.F.R. 91.405 (a)
14 C.F.R. 407 (a) (1)
14 C.F.R. 409 (a) (2)
14 C.F.R. 417 (a) & (b)
NFL Films proposes that it receive an exemption to use sUAS to gather footage from
closed-set locations in and around NFL stadiums (on non-game days) and NFL practice
facilities. NFL Films would use the footage for the production of television programs. NFL
Films would obtain the consent of all personnel in the stadiums and practice facilities in the
vicinity in which the sUAS may operate.
The proposed sUAS operation will be conducted safely to minimize risk to the national
airspace system (NAS) or to persons and property on the ground. NFL Films proposes that
the exemption apply to civil aircraft that operate within the limitations listed below. These
limitations were established in the FAAs grant of Advanced Aerial Cinematographys request for
an exemption:
1. The sUAS will weigh less than 55 pounds, including payload. Proposed
operations of any other aircraft will require a new petition or a petition to amend
this exemption.
2. Operations for the purpose of closed-set motion picture and television filming are
permitted.
3. The sUAS may not be operated at a speed exceeding 87 knots (100 miles per
hour). NFL Films may use either groundspeed or calibrated airspeed to
determine compliance with the 87 knot speed restriction. In no case will the UA

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May 20, 2015
Page 3

be operated at airspeeds greater than the maximum UA operating airspeed

recommended by the aircraft manufacturer.
4. The UA will be operated at an altitude of no more than 400 feet above ground
level (AGL). Altitude will be reported in feet AGL.
5. The UA will be operated within visual line of sight (VLOS) of the Pilot in Charge
(PIC) at all times. This requires the PIC to be able to use human vision unaided
by any device other than corrective lenses, as specified on the PICs FAA-issued
airman medical certificate or U.S. drivers license.
6. All operations will utilize a visual observer (VO). The UA will be operated within
the VLOS of the PIC and VO at all times. The VO may be used to satisfy the VLOS
requirement as long as the PIC always maintains the VLOS capability. The VO
and PIC will be able to communicate verbally at all times; electronic messaging or
texting will not be permitted during flight operations. The PIC will be designated
before the flight and cannot transfer his or her designation for the duration of the
flight. The PIC will ensure that the VO can perform the duties required of the VO.
7. This exemption and all documents needed to operate the sUAS and conduct its
operations in accordance with the conditions and limitations stated in the grant
of exemption, are hereinafter referred to as the operating documents. The
operating documents will be accessible during sUAS operations and made
available to the Administrator upon request. If a discrepancy exists between the
conditions and limitations in the exemption and the procedures outlined in the
operating documents, the conditions and limitations herein take precedence and
will be followed. Otherwise, NFL Films will follow the procedures as outlined in
its operating documents. NFL Films may update or revise its operating
documents. It is NFL Films responsibility to track such revisions and present
updated and revised documents to the Administrator or any law enforcement
official upon request. NFL Films will also present updated and revised
documents if it petitions for extension or amendment to this grant of exemption.
If NFL Films determines that any update or revision would affect the basis upon
which the FAA granted this exemption, then NFL Films must petition for an
amendment to its grant of exemption. The FAAs UAS Integration Office (AFS80) may be contacted if questions arise regarding updates or revisions to the
operating documents.
8. Any UAS that has undergone maintenance or alterations that affect the UAS
operation or flight characteristics, e.g., replacement of a flight critical component,
must undergo a functional test flight prior to conducting further operations
under this exemption. Functional test flights may only be conducted by a PIC
with a VO and must remain at least 500 feet from other people. The functional
test flight must be conducted in such a manner so as to not pose an undue hazard
to persons and property.

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May 20, 2015
Page 4

9. NFL Films is responsible for maintaining and inspecting the UAS to ensure that it
is in a condition for safe operation.
10. Prior to each flight, the PIC will conduct a pre-flight inspection and determine
the sUAS is in a condition for safe flight. The pre-flight inspection will account
for all potential discrepancies, e.g., inoperable components, items, or equipment.
If the inspection reveals a condition that affects the safe operation of the sUAS,
the aircraft will be prohibited form operating until the necessary maintenance
has been performed and the sUAS is found to be in a condition for safe flight.
11. NFL Films will follow the sUAS manufacturers maintenance, overhaul,
replacement, inspection, and life limit requirements for the aircraft and aircraft
components.
12. Each sUAS operated under this exemption will comply with all manufacturer
safety bulletins.
13. Under this grant of exemption, a PIC will hold either an airline transport,
commercial, private, recreational, or sport pilot certificate. The PIC will also hold
a current FAA airman medical certificate or a valid U.S. drivers license issued by
a state, the District of Columbia, Puerto Rico, a territory, a possession, or the
Federal Government. The PIC also will meet the flight review requirements
specified in 14 CFR 61.56 in an aircraft in which the PIC is rated on his or her
pilot certificate.
14. NFL Films will not permit any PIC to operate unless the PIC demonstrates the
ability to safely operate the sUAS in a manner consistent with how the sUAS will
be operated under this exemption, including evasive and emergency maneuvers
and maintaining appropriate distances from persons, vessels, vehicles, and
structures. PIC qualification flight hours and currency will be logged in a manner
consistent with 14 CFR 61.51(b). Flights for the purposes of training the
operators PICs and VOs (training, proficiency, and experience-building) and
determining the PICs ability to safely operate the sUAS in a manner consistent
with how the sUAS will be operated under this exemption are permitted under
the terms of this exemption. However, training operations may only be
conducted during dedicated training sessions. During training, proficiency, and
experience-building flights, all persons not essential for flight operations are
considered nonparticipants, and the PIC will operate the UA with appropriate
distance from nonparticipants in accordance with 14 CFR 91.119.
15. UAS operations will not be conducted during night, as defined in 14 C.F.R. 1.1.
All operations will be conducted under visual meteorological conditions (VMC).
NFL Films will not operate flights under special visual flight rules (SVFR).
16. The UA will not operate within 5 nautical miles of an airport reference point
(ARP) as denoted in the current FAA Airport/Facility Director (AFD) or for
airports not denoted with an ARP, the center of the airport symbol as denoted on

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Page 5

the current FAA-published aeronautical chart, unless a letter of agreement with

that airports management is obtained or otherwise permitted by a COA issued to
the exemption holder. The letter of agreement with the airport management will
be made available to the Administrator or any law enforcement official upon
request.
17. The UA will not be operated less than 500 feet below or less than 2,000 feet
horizontally from a cloud or when visibility is less than 3 statute miles from the
PIC.
18. If the sUAS loses communications or loses its GPS signal, the UA will return to a
pre-determined location within the private or controlled-access property.
19. The PIC will abort the flight in the event of unpredicted obstacles or emergencies.
20. The PIC will be prohibited from beginning a flight unless (considering wind and
forecast weather conditions) there is enough available power for the UA to
conduct the intended operation and to operate after that for at least five minutes
or with the reserve power recommended by the manufacturer if greater.
21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All
operations will be conducted in accordance with an ATO-issued COA. The
exemption holder may apply for a new or amended COA if it intends to conduct
operations that cannot be conducted under the terms of the attached COA.
22. All aircraft operated in accordance with this exemption will be identified by serial
number, registered in accordance with 14 CFR part 47, and have identification
(N-Number) markings in accordance with 14 CFR part 45, Subpart C. Markings
will be as large as practicable.
23. Documents used by NFL Films to ensure the safe operation and flight of the sUAS
and any documents required under 14 CFR 91.9 and 91.203 will be available to
the PIC at the Ground Control Station of the sUAS any time the aircraft is
operating. These documents will be made available to the Administrator or any
law enforcement official upon request.
24. The UA will remain clear and give way to all manned aviation operations and
activities at all times.
25. The sUAS will not be operated by the PIC from any moving device or vehicle.
26. All Flight operations will be conducted at least 500 feet from all nonparticipating
persons, vessels, vehicles, and structures, unless:
a. Barriers or structures are present that sufficiently protect
nonparticipating persons from the UA and/or debris in the event of an
accident. NFL Films will ensure that nonparticipating persons remain

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Page 6

under such protection. If a situation arises where nonparticipating

persons leave such protection and are within 500 feet of the UA, flight
operations will cease immediately in a manner ensuring the safety of
nonparticipating persons; and
b. The owner/controller of any vessels, vehicles or structures has granted
permission for operating closer to those objects and the PIC has made a
safety assessment of the risk of operating closer to those objects and
determined that it does not present an undue hazard.
The PIC, VO, operator trainees, essential persons, or individuals who have signed
consent forms are not considered nonparticipating persons under this
exemption.
27. All operations will be conducted over private or controlled-access property with
permission from the property owner/controller or authorized representative.
Permission from property owner/controller or authorized representative will be
obtained for each flight to be conducted.
28. Any incident, accident, or flight operation that transgresses the lateral or vertical
boundaries of the operational area as defined by the applicable COA will be
reported to the FAAs UAS Integration Office (AFS-80) within 24 hours.
Accidents will be reported to the National Transportation Safety Board (NTSB)
per instructions contained on the NTSB Web site: www.ntsb.gov.
If this exemption permits operations for the purpose of closed-set motion picture and
television filming and production, the following additional conditions and limitations
apply:
29. NFL Films will have a motion picture and television operations manual
(MPTOM) as documented in this grant of exemption.
30. At least 3 days before aerial filming, NFL Films will submit a written Plan of
Activities to the local Flight Standards District Office (FSDO) with jurisdiction
over the area of proposed filming. The 3-day notification may be waived with the
concurrence of the FSDO. The plan of activities must include at least the
following:
a. Dates and times for all flights;
b. Name and phone number of the operator for the sUAS aerial filming
conducted under this grant of exemption;
c. Name and phone number of the person responsible for the on-scene
operation of the sUAS;
d. Make, model, and serial or N-Number of the sUAS to be used;

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May 20, 2015
Page 7

e. Name and certificate number of sUAS PICs involved in the aerial filming;
f.

A statement that the operator has obtained permission from property

owners and/or local officials to conduct the filming production event; the
list of those who gave permission will be made available to the inspector
upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any
area, city, town, county, and/or state over which filming will be conducted
and the altitudes essential to accomplish the operation.
31. Flight operations may be conducted closer than 500 feet from participating
persons consenting to be involved and necessary for the filming production, as
specified in the exemption holders MPTOM.
Unless otherwise specified, the sUAS operations will comply with all applicable parts of
14 CFR including, but not limited to, parts 45, 47, 61, and 91. NFL Films incorporates all
arguments in support of the petition made in Advanced Aerial Cinematographys November 24,
2014 application for exemption.
Federal Register Notice
As stated above, publication in the Federal Register is unnecessary because this
application meets the FAAs criteria for summary approval. To the extent that the FAA
determines that publication is necessary, the following summary is provided:
Applicant seeks an exemption from the following rules: 14 C.F.R. 21,
subpart H; 14 C.F.R 45.23 (b); 14 C.F.R. 61.113 (a) & (b); 91.7 (a); 91.9
(b)(2); 91.103 (b); 91.109; 91.119; 91.121; 91.151(a); 91.203 (a) and (b);
91.405 (a); 91.407 (a)(1); 91.409 (a)(2); 91.409 (a)(2) and 91.417 (a) & (b)
to operate commercially a small unmanned vehicle (55 lbs or less) in
videography operations.
The Exemption is in the Public Interest
As demonstrated above, the proposed sUAS operations would minimize the risk of harm
to individual safety or damage to the NAS and property. The operations proposed by NFL Films
would provide tremendous public benefits by enabling millions of NFL fans to view footage that
could not be captured via any other technology. The sUAS operations as described in this
application will be far safer and more efficient than use of helicopters or other aircraft to capture
the required footage.
The conditions outlined in this petition clearly satisfy Section 333s exemption criteria
regarding size, weight, speed, operational capability, proximity to airports and populated areas,
and operation within visual line of sight, and therefore the proposed operations would not

U.S. Department of Transportation

May 20, 2015
Page 8

create a hazard to users of the national airspace system or the public or pose a threat to
national security. As discussed above, NFL Films agrees to use limitations that are substantially
identical to those contained in the FAAs recent grant of exemption for Advanced Aerial
Cinematography. Accordingly, the proposed UAS operations of NFL Films should not raise
safety or national security concerns, and should receive summary approval.
Please do not hesitate to contact the undersigned if you need additional information.
Respectfully submitted,

Kurt Wimmer
Jeff Kosseff

Filed Electronically Via Regulations.gov

August 11, 2015

Dan Ngo
FAA Office of Rulemaking
800 Independence Ave. SW
Washington, DC 20591
Re: FAA-2015-2139
Dear Mr. Ngo:
Attached please find a Motion Picture and Television Operations Manual (MPTOM)
prepared by NFL Films for the above-referenced docket. The MPTOM includes, at Appendix B,
a description of the aircraft makes, models, and types, as requested, for the proposed UAS
operation.
This letter and the attachment were filed online at regulations.gov in Docket No. FAA2015-2139.
Please contact me if you have any questions.
Sincerely,
/s/ Stephen Kiehl
Stephen Kiehl

Attachment

DC: 5806013-1

Motion Picture and Television

Flight Operation Manual

NFL Productions LLC d/b/a NFL Films

One Sabol Way
Mt. Laurel, NJ 08054
(856) 222-3545 | (856) 291-5455 (Fax)

Date: August 11, 2015

Version: Original

Table of Contents
A.

Purpose............................................................................................................................... 4

B.

Pilot/Operator Organization ............................................................................................ 4

C.

Pilots To Be Used During Filming ................................................................................... 4

D.

List of Aircraft by Make, Model and Serial or Registration Number ......................... 4

E.

Distribution and Revision ................................................................................................ 4

F.

Persons Authorized ........................................................................................................... 5

G.

Area of Operations ............................................................................................................ 5

H.

Plan of Activities ............................................................................................................... 8

I.

Permission to Operate ...................................................................................................... 9

J.

Security .............................................................................................................................. 9

K.

Briefing of Pilots and Production Personnel ................................................................ 10

L.

Certification/Airworthiness ........................................................................................... 10

M.

Pilot PersonnelMinimum Requirements................................................................... 10

N.

Limitations ....................................................................................................................... 10

O.

Communications ............................................................................................................. 10

P.

Accident Notification ...................................................................................................... 11

Q.

Recall/Stop Procedures ................................................................................................... 11

R.

Aerobatic Competency ................................................................................................... 11

Appendix A
Appendix B
Appendix C

Page 2 of 14

Revision Control Page

Revision #

Date

Initials

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Motion Picture and Television Flight Operation Manual

A.

Purpose

This Manual has been developed by NFL Productions LLC d/b/a NFL Films (NFL Films) in
conjunction with an application for an exemption from a limited number of regulations pursuant
to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, as
outlined in NFL Films exemption application dated May 20, 2015, for use of sUAS to gather
footage from closed-set locations in and around NFL stadiums (on non-game days) and NFL
practice facilities. NFL Films pilots and other company personnel when applicable will comply
with the policies, procedures, and conditions of this Manual, whenever motion picture or
television flight operations are performed that require an exemption.
B.

Pilot/Operator Organization

NFL Productions LLC d/b/a NFL Films -- Operator

One Sabol Way
Mt. Laurel, NJ 08054
Barry M. Wolper - Chief Financial Officer and applicant/responsible person - (856) 222-3545
C.

Pilots To Be Used During Filming

Pilots to be used during filming will be included in the Plan of Activities to be filed at least three
(3) days prior to each scheduled filming, pursuant to Section H, infra, with the local FSDO
having jurisdiction over the area of proposed filming. The list of pilots will include each pilots
pilot certificate number as well as special pilot authorizations or endorsements, if applicable.
D.

List of Aircraft by Make, Model and Serial or Registration Number

A list of aircraft to be used appears in Appendix B, infra. Furthermore, any aircraft to be used in
the proposed filming shall be listed by make, model and serial or registration number in the Plan
of Activities to be filed at least three days prior to each scheduled filming, pursuant to Section H,
infra, with the local FSDO having jurisdiction over the area of proposed filming.
E.

Distribution and Revision

NFL Films will issue a copy of this manual, including all revisions, to all personnel involved in
sUAS operation. All recipients are required to keep their manuals up-to-date with any furnished
revisions.
Amendments in FARs and normal usage will frequently indicate a need for additions, deletions,
or corrections of selected subject matter in this manual. Revisions to the manual will be issued
periodically to reflect these changes. In addition, manual users who observe or experience a
need for change are encouraged to submit their suggestions to the Chief Financial Officer for
review and consideration.
Revisions to the Manual will be forwarded to the Flight Standards District Office (FSDO) at
least 15 days before the proposed effective date. Revisions will be noted on the Revision
Page 4 of 14

Control Page at the front of this Manual and will be noted in bold in this Manual. Each
subsequent revision of the Manual will be distributed to all company personnel involved in
sUAS operation.
F.

Persons Authorized

Section 91.119(c) is waived only with respect to those participating persons, vehicles, and
structures directly involved in the performance of the actual filming. The pilot-in-command and
certificate holder shall ensure that no persons are allowed within 500 feet of the area except those
consenting to be involved and necessary for the filming production. This provision may be
reduced to no less than 200 feet in the event that a suitable, equivalent level of safety can be
achieved. An equivalent level of safety may be determined by evaluation of the filming
production area and the degree of terrain features, buildings, etc. that will provide a safety barrier
to observers.
Prior to any filming, the pilot-in-command and certificate holder shall be responsible for
obtaining signed consent forms from any person who is allowed within 500 feet (or 200 feet as
outlined above) of the filming. Such consent forms shall be maintained by the operator for a
period of at least six (6) months following the filming.
G.

Area of Operations

The area of operations shall cover all NFL stadiums and practice facilities in the United States,
including:
NFL Stadiums
Arizona Cardinals
University of Phoenix Stadium
Glendale, AZ 85305

Miami Dolphins
Sun Life Stadium
Miami Gardens, FL 33056

Atlanta Falcons
Georgia Dome
Atlanta, GA 30313

Minnesota Vikings
TCF Bank Stadium
Minneapolis, MN 55455

Baltimore Ravens
M&T Bank Stadium
Baltimore, MD 21230

New England Patriots

Gillette Stadium
Foxboro, MA 02035

Buffalo Bills
Ralph Wilson Stadium
Orchard Park, NY 14127

New Orleans Saints

Mercedes-Benz Superdome
New Orleans, LA 70112

Carolina Panthers
Bank of America Stadium
Charlotte, NC 28202

New York Giants

MetLife Stadium
East Rutherford, NJ 07073

Page 5 of 14

Chicago Bears
Soldier Field
Chicago, IL 60605

New York Jets

MetLife Stadium
East Rutherford, NJ 07073

Cincinnati Bengals
Paul Brown Stadium
Cincinnati, OH

Oakland Raiders
O.co Coliseum
Oakland, CA 94621

Cleveland Browns
FirstEnergy Stadium
Cleveland, OH 44114

Philadelphia Eagles
Lincoln Financial Field
Philadelphia, PA 19148

Dallas Cowboys
Cowboys Stadium
Arlington, TX 76011

Pittsburgh Steelers
Heinz Field
Pittsburgh, PA 15212-5721

Denver Broncos
Sports Authority Field at Mile High
Denver, CO 80204

St. Louis Rams

Edward Jones Dome
St. Louis, MO 63101

Detroit Lions
Ford Field
Detroit, MI 48226

San Diego Chargers

Qualcomm Stadium
San Diego, CA 92108

Green Bay Packers

Lambeau Field
Green Bay, WI 54304

San Francisco 49ers

Levis Stadium
Santa Clara, CA 95054

Houston Texans
NRG Stadium
Houston, TX 77054

Seattle Seahawks
CenturyLink Field
Seattle, WA 98104

Indianapolis Colts
Lucas Oil Stadium
Indianapolis, IN

Tampa Bay Buccaneers

Raymond James Stadium
Tampa, FL 33607

Jacksonville Jaguars
EverBank Field
Jacksonville, FL 32202

Tennessee Titans
Nissan Stadium
Nashville, TN 37213

Kansas City Chiefs

Arrowhead Stadium
Kansas City, MO 64129

Washington Redskins
FedEx Field
Landover, MD 20785

Page 6 of 14

NFL Practice Facilities

Arizona Cardinals
University of Phoenix Stadium
Glendale, AZ 85305

Miami Dolphins
Miami Dolphins Training Facility
Davie, FL 33314

Atlanta Falcons
Atlanta Falcons Training Complex
Flowery Branch, GA 30542

Minnesota Vikings
Minnesota State University Mankato
Mankato, MN 56001

Baltimore Ravens
Baltimore Ravens Under Armour Performance
Center
Owings Mills, MD 21117

New England Patriots

Gillette Stadium
Foxboro, MA 02035

Buffalo Bills
St. John Fisher College
Rochester, NY 14618

New Orleans Saints

The Greenbrier
White Sulpher Springs, WV 24986

Carolina Panthers
Wofford College
Spartanburg, SC 29303-3663

New York Giants

Quest Diagnostics Training Center
1925 Giants Drive
East Rutherford, NJ 07073

Chicago Bears
Olivet Nazarene University
Bourbonnais, IL 60914

New York Jets

Atlantic Health Jets Training Center
Florham Park, NJ 07932

Cincinnati Bengals
Paul Brown Stadium
Cincinnati, OH 45202

Oakland Raiders
Napa Valley Marriott Hotel
Napa, CA 94558

Cleveland Browns
Cleveland Browns Training Facility
Berea, OH 44017

Philadelphia Eagles
NovaCare Complex/Lincoln Financial Field
Philadelphia, PA 19145

Dallas Cowboys
Marriott Residence Inn
Oxnard, CA 93036

Pittsburgh Steelers
St. Vincents College
Latrobe, PA 15650

Cowboys Center
Irving, TX 75063-4999

UPMC Sports Performance Complex

Pittsburgh, PA 15203-2349

Denver Broncos
Paul D. Bowlen Memorial Broncos Center
Englewood, CO 80112

St. Louis Rams

Rams Park Training Facility
Earth City, MO 63045

Page 7 of 14

Detroit Lions
Detroit Lions Training Facility
Allen Park, MI 48101

San Diego Chargers

Chargers Park
San Diego, CA 92123

Green Bay Packers

St. Norbert College/Don Hutson Center
Green Bay, WI 54304

San Francisco 49ers

SAP Performance Facility & Levis Stadium
Santa Clara, CA 95054

Houston Texans
Houston Texans Practice Facility
Houston, TX 77054

Seattle Seahawks
Seattle Seahawks Headquarters Virginia
Mason Athletic Center
Renton, WA 98056

Indianapolis Colts
Anderson University
Anderson, IN 46012-3495

Tampa Bay Buccaneers

Tampa Bay Buccaneers Training Facility
Tampa, FL 33607

Indiana Farm Bureau Football Center

Indianapolis, IN 46254
Jacksonville Jaguars
EverBank Field
Jacksonville, FL 32202

Tennessee Titans
St. Thomas Sports Park
Nashville, TN 37228

Kansas City Chiefs

Missouri Western State University
St. Joseph, MO 64506

Washington Redskins
Bon Secours Washington Redskins Training
Center
Richmond, VA 23220

The pilot/operator shall coordinate with the FSDO having geographic responsibility over the area
of the filming operations.
H.

Plan of Activities

At least three (3) days prior to any scheduled filming, NFL Films shall submit a written plan of
activities to the local FSDO having jurisdiction over the area of proposed filming. The plan of
activities shall include the following:
1)

Dates and times for all flights.

2)

Name and phone number of operator responsible for the filming production
event.
Name and phone number of the person responsible for the on-scene operation
of the sUAS.

3)

4)

Make, model, and serial number or registration number of aircraft to be used

and type of airworthiness certificate, including Category (CAT).
Page 8 of 14

5)

Names and certificate numbers of pilots involved in the filming production

event.

6)

A statement that permission has been obtained from property owners and/or
local officials to conduct the filming production event; the list of those who
gave permission will be made available to the inspector upon request.

7)

Signature of exemption holder or a designated representative.

8)

A general outline, description or summary of the flight activity schedule,

including maps or diagrams of any area, city, town, country, and/or state over
which filming will be conducted and the altitude essential to accomplish the
operation.

At the discretion of the FSDO, the 3-day notification may be waived. Justification of the
exception to the 3-day requirement is needed.
NFL Films acknowledges that prior to the beginning of any filming operations, the plan of
activities must be accepted by the FAA.
I.

Permission to Operate

Before any flight operation is conducted at less than 500 feet under the provisions of the
certificate of waiver and this Manual, the operator will obtain permission to conduct these
operations from property owners and local officials as necessary or appropriate. Persons from
whom permission may be required are listed below:
1)

Property owners

2)

Law enforcement officials

3)

Fire department officials

4)

Local, state and federal government

The NFL Films personnel obtaining such permission will do so in writing whenever practical;
however, verbal permission is acceptable otherwise. A standard permission form is provided in
Appendix A and may be used when obtaining written permission. Written permission forms will
be maintained at the job site until flight operations are completed, and then turned over to NFL
Films to be kept on file for a minimum of six (6) months. These forms will be made available
for inspection by the FAA or other official personnel upon request.
J.

Security

Prior to any flight operation, the operator will coordinate with appropriate production personnel
to devise a plan of securing the area(s) of operation from all unauthorized persons, vehicles and
Page 9 of 14

aircraft. Provisions will be made to immediately discontinue operations should the area(s)
become unsecured or for any other reason in the interest of safety.
K.

Briefing of Pilots and Production Personnel

Prior to the start of any operation under the provisions of this Manual, the pilot in command will
conduct a briefing of all procedures to participating personnel of the risks involved, emergency
procedures, and safeguards to be following during the filming production event. Personnel will
also be briefed on any additional provisions that may be issued by the local FSDO, including the
location of boundaries or any other time limits.
L.

Certification/Airworthiness

Prior to any flight operation, the pilot in command will conduct a pre-flight inspection in
accordance with Title 14 of the Code of Federal Regulations (14 CFR) parts 43 and 91 and
applicable operating limitations. The pre-flight inspection will account for all potential
discrepancies, e.g., inoperable components, items or equipment. If the inspection reveals a
condition that affects the safe operation of the sUAS, the aircraft will be prohibited from
operation until the necessary maintenance has been performed and the sUAS is found to be in a
condition for safe flight.
NFL Films will follow the sUAS manufacturers maintenance, overhaul, replacement, inpsection
and life limit requirements for the aircraft and aircraft components. Each sUAS operated under
this exemption will comply with all manufacturer safety bulletins.
The aircraft to be used may be certificated in any CAT, including experimental, provided the
requirements of 14 CFR part 91, 91.7, 91.9, and 91.203 are met.
M.

Pilot PersonnelMinimum Requirements

The pilot in command will hold either an airline transport, commercial, private, recreational, or
sport pilot certificate. The PIC will also hold a current FAA airman medical certificate or a valid
U.S. drivers license issued by a state, the District of Columbia, Puerto Rico, a territory, a
possession, or the Federal Government. The PIC also will meet the flight review requirements
specified in 14 CFR 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.
N.

Limitations

Aircraft operations shall conform with the limitations set forth in NFL Films request for a
limited exemption, dated May 20, 2015, attached to this Manual as Appendix C.
The aircraft will be operated at an altitude of no more than 400 feet above ground level (AGL).
Altitude will be reported in feet AGL.
The aircraft will not be operated during night, as defined in 14 CFR 1.1.
O.

Communications

Page 10 of 14

Prior to the start of any operation covered by this Manual, the pilot in command will formulate a
plan to provide communications capability to all participants during the actual operation and
filming. Oral, visual or radio communications may be used as long as it is effective and is
capable of keeping the participants continuously apprised of the current status of the operation.
P.

Accident Notification

Should an accident or incident requiring notification of the NTSB occur, the operator would
immediately notify the NTSB pursuant to 49 CFR 830 and take steps to preserve and protect
the accident scene.
Q.

Recall/Stop Procedures

Radio communication, oral, visual or a combination will be utilized to keep the participants
continuously apprised of the current status of operation.
R.

Aerobatic Competency

If the filming operations require the issuance of FAA Form 8710-7, see Volume 5, Chapter 9,
Section 1, Issue/Renew/Rescind a Statement of Acrobatic Competency.

Page 11 of 14

Appendix A

NFL Films
Permission to Conduct Operations Form
In signing this form, I am giving NFL Films permission to operate its aircraft at less than
500 feet from property, or, in some jurisdiction in which I am responsible for or affiliated
with, for the purpose of film or television production.
Name:

____________________________

Title:

____________________________

Location:

____________________________

Date of
Operation:

____________________________

Basis of Authority to Grant Permission:

______________________________________________________________________

Signature:

____________________________

Date:

____________________________

NFL Films Representative Receiving Permission:

________________________________________

Page 12 of 14

Appendix B

NFL Films
List of Approved Aircraft
Make and Model

Type

Weight

DJI Innovations Phantom 1

Quad-rotor

3 lbs. (inclusive of
camera and battery)

DJI Innovations Phantom 2

Quad-rotor

3 lbs. (inclusive of
camera and battery)

DJI Innovations Inspire 1

Quad-rotor

6 lbs. (inclusive of
camera and battery)

Page 13 of 14

Appendix C

NFL Films Letter Requesting Limited Exemptions

Page 14 of 14

May 20, 2015

U.S. Department of Transportation
Document Management System
1200 New Jersey Ave., SE
Washington, DC 20590
To Whom It May Concern:
Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14
C.F.R., Part 11, NFL Productions LLC d/b/a NFL Films (NFL Films), operator of Small
Unmanned Aircraft Systems (sUAS) equipped to conduct aerial videography of professional
football game and training facilities, requests a limited exemption from the below-listed
regulations to allow commercial operation of its sUASs, provided that the proposed sUAS
operations comply with the conditions outlined below or as established by the Federal Aviation
Administration (FAA) under Section 333.
The name and address of the applicant is: NFL Productions LLC, One Sabol Way, Mt.
Laurel, N.J. 08054, c/o Barry M. Wolper, Chief Financial Officer, (856) 222-3545,
barry.wolper@nfl.com.
NFL Films makes this request under the summary grant process that the FAA
announced in April 2015. 1 This request is similar in all material respects to a number of recent
grants of exemption, including Grant of Exemption No. 11488 to Advanced Aerial
Cinematography, LLC (FAA Docket No. 2014-0090). 2
Regulations from which the exemption is requested:
14 C.F.R. part 21
14 C.F.R. 45.23 (b)
14 C.F.R. 61.113 (a) & (b)
See FAA Summary Grants Speed UAS Exemptions, available at
https://www.faa.gov/news/updates/?newsId=82485.
1

The use limitations and arguments in this application are nearly identical to those contained in
Advanced Aerial Cinematographys November 24, 2014 application and the FAAs May 5, 2015
approval of that application.
2

U.S. Department of Transportation

May 20, 2015
Page 2

14 C.F.R. 91.7 (a)

14 C.F.R. 91.9 (b) (2)
14 C.F.R. 91.103
14 C.F.R. 91.109
14 C.F.R. 91.119
14 C.F.R. 91.121
14 C.F.R. 91.151 (a)
14 C.F.R. 91.203 (a) & (b)
14 C.F.R. 91.405 (a)
14 C.F.R. 407 (a) (1)
14 C.F.R. 409 (a) (2)
14 C.F.R. 417 (a) & (b)
NFL Films proposes that it receive an exemption to use sUAS to gather footage from
closed-set locations in and around NFL stadiums (on non-game days) and NFL practice
facilities. NFL Films would use the footage for the production of television programs. NFL
Films would obtain the consent of all personnel in the stadiums and practice facilities in the
vicinity in which the sUAS may operate.
The proposed sUAS operation will be conducted safely to minimize risk to the national
airspace system (NAS) or to persons and property on the ground. NFL Films proposes that
the exemption apply to civil aircraft that operate within the limitations listed below. These
limitations were established in the FAAs grant of Advanced Aerial Cinematographys request for
an exemption:
1. The sUAS will weigh less than 55 pounds, including payload. Proposed
operations of any other aircraft will require a new petition or a petition to amend
this exemption.
2. Operations for the purpose of closed-set motion picture and television filming are
permitted.
3. The sUAS may not be operated at a speed exceeding 87 knots (100 miles per
hour). NFL Films may use either groundspeed or calibrated airspeed to
determine compliance with the 87 knot speed restriction. In no case will the UA

U.S. Department of Transportation

May 20, 2015
Page 3

be operated at airspeeds greater than the maximum UA operating airspeed

recommended by the aircraft manufacturer.
4. The UA will be operated at an altitude of no more than 400 feet above ground
level (AGL). Altitude will be reported in feet AGL.
5. The UA will be operated within visual line of sight (VLOS) of the Pilot in Charge
(PIC) at all times. This requires the PIC to be able to use human vision unaided
by any device other than corrective lenses, as specified on the PICs FAA-issued
airman medical certificate or U.S. drivers license.
6. All operations will utilize a visual observer (VO). The UA will be operated within
the VLOS of the PIC and VO at all times. The VO may be used to satisfy the VLOS
requirement as long as the PIC always maintains the VLOS capability. The VO
and PIC will be able to communicate verbally at all times; electronic messaging or
texting will not be permitted during flight operations. The PIC will be designated
before the flight and cannot transfer his or her designation for the duration of the
flight. The PIC will ensure that the VO can perform the duties required of the VO.
7. This exemption and all documents needed to operate the sUAS and conduct its
operations in accordance with the conditions and limitations stated in the grant
of exemption, are hereinafter referred to as the operating documents. The
operating documents will be accessible during sUAS operations and made
available to the Administrator upon request. If a discrepancy exists between the
conditions and limitations in the exemption and the procedures outlined in the
operating documents, the conditions and limitations herein take precedence and
will be followed. Otherwise, NFL Films will follow the procedures as outlined in
its operating documents. NFL Films may update or revise its operating
documents. It is NFL Films responsibility to track such revisions and present
updated and revised documents to the Administrator or any law enforcement
official upon request. NFL Films will also present updated and revised
documents if it petitions for extension or amendment to this grant of exemption.
If NFL Films determines that any update or revision would affect the basis upon
which the FAA granted this exemption, then NFL Films must petition for an
amendment to its grant of exemption. The FAAs UAS Integration Office (AFS80) may be contacted if questions arise regarding updates or revisions to the
operating documents.
8. Any UAS that has undergone maintenance or alterations that affect the UAS
operation or flight characteristics, e.g., replacement of a flight critical component,
must undergo a functional test flight prior to conducting further operations
under this exemption. Functional test flights may only be conducted by a PIC
with a VO and must remain at least 500 feet from other people. The functional
test flight must be conducted in such a manner so as to not pose an undue hazard
to persons and property.

U.S. Department of Transportation

May 20, 2015
Page 4

9. NFL Films is responsible for maintaining and inspecting the UAS to ensure that it
is in a condition for safe operation.
10. Prior to each flight, the PIC will conduct a pre-flight inspection and determine
the sUAS is in a condition for safe flight. The pre-flight inspection will account
for all potential discrepancies, e.g., inoperable components, items, or equipment.
If the inspection reveals a condition that affects the safe operation of the sUAS,
the aircraft will be prohibited form operating until the necessary maintenance
has been performed and the sUAS is found to be in a condition for safe flight.
11. NFL Films will follow the sUAS manufacturers maintenance, overhaul,
replacement, inspection, and life limit requirements for the aircraft and aircraft
components.
12. Each sUAS operated under this exemption will comply with all manufacturer
safety bulletins.
13. Under this grant of exemption, a PIC will hold either an airline transport,
commercial, private, recreational, or sport pilot certificate. The PIC will also hold
a current FAA airman medical certificate or a valid U.S. drivers license issued by
a state, the District of Columbia, Puerto Rico, a territory, a possession, or the
Federal Government. The PIC also will meet the flight review requirements
specified in 14 CFR 61.56 in an aircraft in which the PIC is rated on his or her
pilot certificate.
14. NFL Films will not permit any PIC to operate unless the PIC demonstrates the
ability to safely operate the sUAS in a manner consistent with how the sUAS will
be operated under this exemption, including evasive and emergency maneuvers
and maintaining appropriate distances from persons, vessels, vehicles, and
structures. PIC qualification flight hours and currency will be logged in a manner
consistent with 14 CFR 61.51(b). Flights for the purposes of training the
operators PICs and VOs (training, proficiency, and experience-building) and
determining the PICs ability to safely operate the sUAS in a manner consistent
with how the sUAS will be operated under this exemption are permitted under
the terms of this exemption. However, training operations may only be
conducted during dedicated training sessions. During training, proficiency, and
experience-building flights, all persons not essential for flight operations are
considered nonparticipants, and the PIC will operate the UA with appropriate
distance from nonparticipants in accordance with 14 CFR 91.119.
15. UAS operations will not be conducted during night, as defined in 14 C.F.R. 1.1.
All operations will be conducted under visual meteorological conditions (VMC).
NFL Films will not operate flights under special visual flight rules (SVFR).
16. The UA will not operate within 5 nautical miles of an airport reference point
(ARP) as denoted in the current FAA Airport/Facility Director (AFD) or for
airports not denoted with an ARP, the center of the airport symbol as denoted on

U.S. Department of Transportation

May 20, 2015
Page 5

the current FAA-published aeronautical chart, unless a letter of agreement with

that airports management is obtained or otherwise permitted by a COA issued to
the exemption holder. The letter of agreement with the airport management will
be made available to the Administrator or any law enforcement official upon
request.
17. The UA will not be operated less than 500 feet below or less than 2,000 feet
horizontally from a cloud or when visibility is less than 3 statute miles from the
PIC.
18. If the sUAS loses communications or loses its GPS signal, the UA will return to a
pre-determined location within the private or controlled-access property.
19. The PIC will abort the flight in the event of unpredicted obstacles or emergencies.
20. The PIC will be prohibited from beginning a flight unless (considering wind and
forecast weather conditions) there is enough available power for the UA to
conduct the intended operation and to operate after that for at least five minutes
or with the reserve power recommended by the manufacturer if greater.
21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All
operations will be conducted in accordance with an ATO-issued COA. The
exemption holder may apply for a new or amended COA if it intends to conduct
operations that cannot be conducted under the terms of the attached COA.
22. All aircraft operated in accordance with this exemption will be identified by serial
number, registered in accordance with 14 CFR part 47, and have identification
(N-Number) markings in accordance with 14 CFR part 45, Subpart C. Markings
will be as large as practicable.
23. Documents used by NFL Films to ensure the safe operation and flight of the sUAS
and any documents required under 14 CFR 91.9 and 91.203 will be available to
the PIC at the Ground Control Station of the sUAS any time the aircraft is
operating. These documents will be made available to the Administrator or any
law enforcement official upon request.
24. The UA will remain clear and give way to all manned aviation operations and
activities at all times.
25. The sUAS will not be operated by the PIC from any moving device or vehicle.
26. All Flight operations will be conducted at least 500 feet from all nonparticipating
persons, vessels, vehicles, and structures, unless:
a. Barriers or structures are present that sufficiently protect
nonparticipating persons from the UA and/or debris in the event of an
accident. NFL Films will ensure that nonparticipating persons remain

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under such protection. If a situation arises where nonparticipating

persons leave such protection and are within 500 feet of the UA, flight
operations will cease immediately in a manner ensuring the safety of
nonparticipating persons; and
b. The owner/controller of any vessels, vehicles or structures has granted
permission for operating closer to those objects and the PIC has made a
safety assessment of the risk of operating closer to those objects and
determined that it does not present an undue hazard.
The PIC, VO, operator trainees, essential persons, or individuals who have signed
consent forms are not considered nonparticipating persons under this
exemption.
27. All operations will be conducted over private or controlled-access property with
permission from the property owner/controller or authorized representative.
Permission from property owner/controller or authorized representative will be
obtained for each flight to be conducted.
28. Any incident, accident, or flight operation that transgresses the lateral or vertical
boundaries of the operational area as defined by the applicable COA will be
reported to the FAAs UAS Integration Office (AFS-80) within 24 hours.
Accidents will be reported to the National Transportation Safety Board (NTSB)
per instructions contained on the NTSB Web site: www.ntsb.gov.
If this exemption permits operations for the purpose of closed-set motion picture and
television filming and production, the following additional conditions and limitations
apply:
29. NFL Films will have a motion picture and television operations manual
(MPTOM) as documented in this grant of exemption.
30. At least 3 days before aerial filming, NFL Films will submit a written Plan of
Activities to the local Flight Standards District Office (FSDO) with jurisdiction
over the area of proposed filming. The 3-day notification may be waived with the
concurrence of the FSDO. The plan of activities must include at least the
following:
a. Dates and times for all flights;
b. Name and phone number of the operator for the sUAS aerial filming
conducted under this grant of exemption;
c. Name and phone number of the person responsible for the on-scene
operation of the sUAS;
d. Make, model, and serial or N-Number of the sUAS to be used;

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e. Name and certificate number of sUAS PICs involved in the aerial filming;
f.

A statement that the operator has obtained permission from property

owners and/or local officials to conduct the filming production event; the
list of those who gave permission will be made available to the inspector
upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any
area, city, town, county, and/or state over which filming will be conducted
and the altitudes essential to accomplish the operation.
31. Flight operations may be conducted closer than 500 feet from participating
persons consenting to be involved and necessary for the filming production, as
specified in the exemption holders MPTOM.
Unless otherwise specified, the sUAS operations will comply with all applicable parts of
14 CFR including, but not limited to, parts 45, 47, 61, and 91. NFL Films incorporates all
arguments in support of the petition made in Advanced Aerial Cinematographys November 24,
2014 application for exemption.
Federal Register Notice
As stated above, publication in the Federal Register is unnecessary because this
application meets the FAAs criteria for summary approval. To the extent that the FAA
determines that publication is necessary, the following summary is provided:
Applicant seeks an exemption from the following rules: 14 C.F.R. 21,
subpart H; 14 C.F.R 45.23 (b); 14 C.F.R. 61.113 (a) & (b); 91.7 (a); 91.9
(b)(2); 91.103 (b); 91.109; 91.119; 91.121; 91.151(a); 91.203 (a) and (b);
91.405 (a); 91.407 (a)(1); 91.409 (a)(2); 91.409 (a)(2) and 91.417 (a) & (b)
to operate commercially a small unmanned vehicle (55 lbs or less) in
videography operations.
The Exemption is in the Public Interest
As demonstrated above, the proposed sUAS operations would minimize the risk of harm
to individual safety or damage to the NAS and property. The operations proposed by NFL Films
would provide tremendous public benefits by enabling millions of NFL fans to view footage that
could not be captured via any other technology. The sUAS operations as described in this
application will be far safer and more efficient than use of helicopters or other aircraft to capture
the required footage.
The conditions outlined in this petition clearly satisfy Section 333s exemption criteria
regarding size, weight, speed, operational capability, proximity to airports and populated areas,
and operation within visual line of sight, and therefore the proposed operations would not

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Page 8

create a hazard to users of the national airspace system or the public or pose a threat to
national security. As discussed above, NFL Films agrees to use limitations that are substantially
identical to those contained in the FAAs recent grant of exemption for Advanced Aerial
Cinematography. Accordingly, the proposed UAS operations of NFL Films should not raise
safety or national security concerns, and should receive summary approval.
Please do not hesitate to contact the undersigned if you need additional information.
Respectfully submitted,

Kurt Wimmer
Jeff Kosseff